Compliance Blog

Written by JiJi Bahhur, Director of Regulatory Compliance

NCUA to Consider Good Faith Efforts with TILA/RESPA. In response to NAFCU’s request, National Credit Union Administration (NCUA) Chairman Matz responded, recently, that it will take the same examination approach as it did with prior Consumer Financial Protection Bureau (CFPB) mortgage rules.  More specifically, NCUA will consider good faith efforts by credit unions to comply with the CFPB’s Truth in Lending Act and Real Estate Settlement Procedures Act (TILA/RESPA) integrated mortgage disclosure rule.  The TILA/RESPA rule is set to become effective on August 1. 

From Chairman Matz’s response to NAFCU:

“With this new rule, NCUA intends to take the same examination approach used with the implementation of the CFPB’s Qualified Mortgage and Ability-to-Repay rules in 2014.

NCUA examiners will be looking for reasonable and good faith efforts by credit unions toward substantial compliance with the new rule as of the effective date.  NCUA recognizes that some credit unions may need time to perform conclusive system testing and work with their technology vendors to resolve any remaining issues that may occur from extensive testing and use, once their new TILA/RESPA mortgage disclosure systems become fully operational on August 1.”

NAFCU, with 15 other trades, has made a similar request to the CFPB for a restrained examination period.

If you weren’t already having a fabulous Friday, I hope that helped a bit! 

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CFPB’s TILA/RESPA Implementation Materials Updated.  The CFPB has updated its TILA/RESPA regulatory implementation materials to bring them into alignment with the most recent amendments that finalized in February.  We blogged about the finalized amendments here. 

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Programming Note.  With NAFCU’s 2015 Regulatory Compliance School in session from March 30-April 3, please note that NAFCU’s Compliance Team will be heavily involved as faculty and therefore there may be a delay in responses to member questions.  Rest-assured, we’ll get back to you as soon as possible.